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Environmental claims on websites: rules since 27 September

Since 27 September 2026, German unfair competition law bans vague green claims, offset-based climate neutrality and home-made eco seals. How to check your copy.

16 min read UWGUmweltaussagenWerbeaussagenWebsite-TexteRecht

“Eco-friendly”, “climate-neutral”, a green leaf next to the company logo: wording like this appears on many websites of trades businesses, restaurants and service providers, often for years and without any intention to mislead. Since 27 September 2026, new rules apply in Germany (Federal Law Gazette 2026 I No. 43). The Third Act amending the Act against Unfair Competition (UWG) has added, among other things, four practices concerning environmental claims and sustainability labels to the list of commercial practices that are prohibited towards consumers in every case: generic environmental claims without recognised excellent environmental performance, claims about the whole that only concern a part, climate neutrality based on offsetting, and sustainability labels without a certification scheme. This article explains what each item of the annex requires, where its limits lie and how to replace affected sentences with concrete, provable statements. How a website itself can save energy is covered in the article on a website's CO2 footprint; this one is about what the site says about the business. It does not replace legal advice on an individual case.

Review view: environmental claims on the homepageFlagged wording on the left, concrete replacement on the rightsince 27 Sep 2026Homepage · previewYour painting business in the region“Eco-friendly painting”generic environmental claim without proof · no. 4a“Climate-neutral renovation”based on offsetting certificates · no. 4cECOOwn seal “Eco business”no certification scheme · no. 2aReplacement: measure, not labelspecific, provable, on the same pageWall paints with the Blue Angelproduct named in the quote, data sheet on requestWe support a peatland projectnamed as funding, no climate promiseOur measures, each with proofsolar panels on the workshop, e-van in town,repair before replacementUWG Annex no. 2a, 4a, 4c · banned outright towards consumersspecify onlyremovereplacement
  • No. 2a: displaying a sustainability label that is neither based on a certification scheme nor established by public authorities.
  • No. 4a: making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance.
  • No. 4b: making an environmental claim about the entire product or the entire business when it only concerns one aspect or one activity.
  • No. 4c: claiming, on the basis of offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment.
  • No. 10a: presenting requirements that the law imposes on all products of a category as a distinctive feature of your own offer.

What the authorities found in green claims

The new bans have a history, and it plays out online.

In an EU-wide screening of websites, the European Commission and national consumer protection authorities examined 344 seemingly dubious environmental claims in detail (European Commission, 2020 sweep). In 37 percent of cases they found vague and general claims such as “conscious”, “eco-friendly” and “sustainable”; in 59 percent the companies had not provided easily accessible evidence for their claims (European Commission, 2020 sweep). In 42 percent of cases the authorities had reason to believe that the claims could be false or misleading (European Commission, 2020 sweep). A further figure concerns the scope of a claim. In its 2023 proposal for a directive, the Commission described the same sweep in more detail: in 36 percent of cases the authorities found it hard to tell whether a claim referred to the company or only to certain products (European Commission, 2023 proposal). The Commission's 2020 inventory had already rated 53.3 percent of the environmental claims examined as vague, misleading or unfounded, and 40 percent were unsubstantiated (European Commission, 2020 inventory). Labels look similar: of 232 active ecolabels assessed in the EU, almost half had weak verification or none at all (European Commission, 2023 proposal).

Case law was already strict before the amendment. In its judgment of 27 June 2024, the Federal Court of Justice held that an advertisement using an ambiguous environmental term such as “klimaneutral” (climate-neutral) must, as a rule, explain within the advertisement itself which specific meaning applies (Federal Court of Justice, I ZR 98/23). Explanatory notes outside the advertisement were not enough for the court. One of its reasons: reducing and offsetting CO2 emissions are not equivalent measures, and from a climate protection perspective reduction takes priority. The new annex items go further: they no longer just require an explanation, they ban certain claims outright.

No. 4a: generic environmental claims without proof

Item 4a prohibits making a generic environmental claim where the trader cannot demonstrate the recognised excellent environmental performance on which it is based (UWG, Annex no. 4a). The key word is generic.

Under the new definition, an environmental claim is only generic if it is not on a sustainability label and its specification is not given clearly and prominently on the same medium (UWG, Section 2(2)). The directive lists examples including “environmentally friendly”, “eco-friendly”, “green”, “nature's friend”, “ecological”, “climate friendly” and “carbon friendly” (Directive (EU) 2024/825, recital 9). Take care with “sustainable”, “conscious” and “responsible”. According to the directive, such claims should not even be based on recognised excellent environmental performance alone, because they also refer to social characteristics besides environmental ones (Directive (EU) 2024/825, recital 10). Anyone who writes “sustainable” should therefore all the more say what is meant: durable materials, repair before replacement, fair pay in the team or something else.

Two things follow from the definition. First, not every use of “eco-friendly” has been banned since September. If the page states right next to it, clearly visible and on the same page, what the environmental performance consists of, the claim is no longer generic under the definition. The directive illustrates the difference with an example: “climate friendly packaging” is a generic claim, whereas a statement that 100 percent of the energy used to produce this packaging comes from renewable sources is a specific one (Directive (EU) 2024/825, recital 9). The specific statement must then be true and provable, because the general ban on misleading practices still applies to it. Second, it is not only the wording that counts. According to the same recital, a statement combined with colours or images can also amount to a generic environmental claim. A homepage in shades of green with a leaf motif and the sentence “We think about tomorrow” is therefore worth a second look.

The exception that item 4a itself provides does not help most businesses. Recognised excellent environmental performance only means performance in line with Regulation (EC) No 66/2010 on the EU Ecolabel, with officially recognised ecolabels under DIN EN ISO 14024 type I, or with top environmental performance under other Union law (UWG, Section 2(2)). In Germany, the Blue Angel is such a type I ecolabel; more than 70,000 products and services from over 1,800 companies carry it (Blue Angel). Labels like this are awarded to specific products and services under fixed criteria, not to a business as a whole. A painter who uses wall paint with the Blue Angel can say exactly that; it does not make the whole painting business “eco-friendly”.

Scroll table sideways

Generic wordingSpecific and checkableWhat you keep on file
Eco-friendly paintingOn request we paint interior walls with paints that carry the Blue AngelProduct name, data sheet, validity of the label
Green energy in our businessThe roof of our workshop carries a solar installation that covers part of our electricity needsSystem data, annual yield, consumption
Climate-neutral call-outsWithin the city we drive to jobs in an electric van, outside it with dieselVehicle list, service area
Sustainable renovationWe repair windows and doors before we offer a replacementProcess in the quote, examples from practice
Ecological cleaningFor routine cleaning we use products with the EU Ecolabel and dose them as the manufacturer specifiesProduct list with label and licence number
Regional and eco-consciousWe buy vegetables from farms in the area; their origin is shown on the menuSupplier list

The explanation belongs next to the claim

Under the law, an environmental claim is not generic if its specification is given clearly and prominently on the same medium. For a website, that is a strong argument for putting the explanation in the same section, easy to read, not in a footnote and not on a subpage that visitors first have to find. Back in 2024 the Federal Court of Justice did not accept explanatory notes outside the advertisement.

No. 4c: “climate-neutral” through offsetting

Item 4c is the most clearly worded. It prohibits making a claim, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions (UWG, Annex no. 4c). The directive states expressly that product means goods and services alike. As examples it names “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero”, “climate compensated”, “reduced climate impact” and “limited CO2 footprint” (Directive (EU) 2024/825, recital 12). A “climate-neutral bathroom renovation” based on purchased certificates therefore falls squarely under the ban.

According to the directive, such claims remain permissible only if they are based on the actual impact over the life cycle of the product and not on offsetting outside its value chain. At the same time, the directive makes clear that the ban should not prevent companies from advertising their investments in environmental initiatives, including carbon credit projects, as long as this is done in a way that is not misleading (Directive (EU) 2024/825, recital 12). For your website this means: a sentence such as “We support a peatland conservation project in our region” describes what you do. A sentence such as “This makes our work climate-neutral” claims an effect on your service that the law no longer allows where offsetting is involved.

The whole business: no. 4b and targets for tomorrow

Item 4c speaks of the product. Whether it also covers a claim about the business as a whole is left open by the wording; in any case, other rules apply to a “climate-neutral business” or a “sustainable company”.

Without a clearly highlighted specification, such a claim is a generic environmental claim under item 4a, and proof of recognised excellent environmental performance is unlikely to succeed for a business as a whole. Item 4b additionally prohibits environmental claims about the entire business when they only concern a particular activity (UWG, Annex no. 4b). As an example, the directive mentions a trader who creates the impression of using only energy from renewable sources although several of its facilities still run on fossil fuels (Directive (EU) 2024/825, recital 11). Applied to a trades business: the solar installation on the workshop does not make the drives to the building site emission-free.

Targets for the future have their own rule. Anyone who advertises a future environmental performance to consumers, such as “climate-neutral by 2030”, acts misleadingly under the new item 4 of Section 5(3) UWG if this is done without clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan (UWG, Section 5(3) no. 4). The plan must include measurable and time-bound targets, name the allocation of resources and be reviewed regularly by an independent external expert whose findings are made available to consumers. For many small businesses this effort is too great. The better route is then not to write about the future but about what has already been done: the cargo bike for short trips, the heat pump in the workshop, the repair that saves a replacement. Statements like these can be backed up and need no external reviewer.

Another new item concerns matters of course. Under item 10a, it is prohibited to present requirements that apply by law to all products of the category in question on the Union market as a distinctive feature of your own offer (UWG, Annex no. 10a). If you highlight a property that the law requires of all products of this kind anyway as an advantage over other businesses, name it plainly as an obligation or leave it out. How to present prices and other advertising claims properly is explained in the article on pricing and advertising claims.

How to check your website copy

The review can be done in one pass if you work systematically. The order is the same as when decluttering outdated statements: collect first, then classify, then replace.

It is important not to look at the body text only. Environmental claims like to hide in image captions, alt texts, meta descriptions and graphics.

  1. Collect every place. Homepage, about page, service pages, footer, image captions, alt texts, page titles and meta descriptions. Graphics with embedded text belong on the list too.
  2. Search for signal words. The search list below covers the most common terms; add words from your own trade.
  3. Classify every finding. Seal without certification (2a), generic claim (4a), whole instead of part (4b), offsetting (4c), future target (Section 5(3)), legal obligation as an advantage (10a).
  4. Replace or delete. Whatever can be stated specifically and with proof becomes specific. Whatever cannot be proven goes.
  5. File the evidence. Every remaining environmental claim needs proof: data sheet, contract, invoice or certificate with its validity.
  6. Check images and colours. Leaves, globes and green ticks next to a vague claim reinforce it.
  7. Set a reminder. Certificates expire, vehicles get replaced. A date in the calendar for the next review keeps the statements up to date.
Search list for the review
Generic terms (no. 4a, 4b):
  eco-friendly  environmentally friendly  green  eco  ecological
  nature-friendly  climate-friendly  sustainable  conscious
  responsible  carbon-friendly  resource-saving

Offsetting (no. 4c):
  climate-neutral  CO2-neutral  carbon positive  climate positive
  climate compensated  net zero  reduced CO2 footprint

Future targets (Section 5(3) UWG):
  by 20..  on the way to  net zero by  we will be climate-neutral

Seals and symbols (no. 2a):
  own badges, leaf and globe icons, “certified” without a certifier

Replacement pattern:
  What we do + to what extent + since when + which proof

Painting business

Before: “We paint eco-friendly.” After: “For interiors we use wall paints with the Blue Angel; the quote names the paint we will use.”

Plumbing and heating

Before: “Climate-neutral bathroom renovation.” After: “We support a peatland conservation project in the region. It does not reduce the emissions of our work; for that, we use an electric van within the city.”

Café and restaurant

Before: a self-designed seal “Green café”. After: “We buy milk and eggs from farms in the area; the names of the farms are on the menu.”

The AI does not know your evidence

A suggestion from the chat can turn a vague claim into a specific one, but it does not know whether the specific statement is true. Whether the paint really carries the Blue Angel or the van really runs on electricity is something you check yourself before choosing “Apply”. Include the facts in your instruction, for example: “Replace ‘eco-friendly painting’ with: For interiors we use wall paints with the Blue Angel.”

The homepage deserves particular attention in the review, because it carries the statements every visitor reads first; what belongs on the first screen is described in the article on the homepage's first screen. If you offer repairs, you can describe the repair itself instead of writing “sustainable”; how a repair page is set up is shown in the article on the repair page and the European form. How a description of your business becomes a website that you then edit yourself is shown in How XICflow works.

The rule of thumb

Measure, not label: write what you do, to what extent and since when, and keep the evidence ready. “Eco-friendly” says nothing a customer can check; “We paint interior walls with paints that carry the Blue Angel” does.
This article is based on data from: Third Act amending the Act against Unfair Competition (Federal Law Gazette 2026 I No. 43); Act against Unfair Competition (Sections 2, 3 and 5 and annex items 2a, 4a, 4b, 4c and 10a) as published at gesetze-im-internet.de; Directive (EU) 2024/825 (recitals 9 to 12, Article 4); European Commission (press release IP/21/269 on the screening of websites; proposal for a directive on environmental claims, COM(2023) 166); Federal Court of Justice (judgment of 27 June 2024, I ZR 98/23, press release 138/2024); Blue Angel (the German federal government's ecolabel); XICflow documentation (Editor and pages; Working with the AI). Retrieved in October 2026.